New Compliance Rules for Cosmetic Injectables in Queensland – What This Means for Your Clinic

The Queensland Medicines and Poisons Act 2019 (MPA) and Medicines and Poisons (Medicines) Regulation 2021 (MPMR) have introduced strict new compliance requirements that impact how cosmetic clinics, nurse injectors, and even doctor-led practices operate.

While some rules haven't changed, the way they are enforced has tightened significantly, and many clinics that were operating under workarounds, standing orders, or lax prescribing models may now find themselves non-compliant overnight.

If you own or work in a nurse-led clinic or cosmetic injectables business, you need to understand these changes, because non-compliance could mean regulatory action, fines, or even forced closure.

Let’s break down what’s different, what’s unclear, and what you need to do now.

1. No More Standing Orders – Every Patient Requires a New Prescription for Each Treatment

What’s Changed?

✅ Prescribing laws themselves haven't changed, only doctors and nurse practitioners (NPs) can prescribe injectables.
✅ What has changed is enforcement: Every patient now requires a new, individual prescription before every single treatment.
✅ Standing orders are NO LONGER permitted, prescribers cannot pre-approve multiple treatments or issue batch prescriptions for ongoing use.

What This Means for Your Clinic:

🔹 If your clinic was operating under a standing order system where a doctor pre-approved a set number of treatments, that is now illegal.
🔹 Every single treatment session requires a new, patient-specific prescription.
🔹 A doctor or NP must assess and prescribe at the time of consultation, you cannot use an old prescription from a previous visit.

🚨 Risk of Non-Compliance:

• If an injector continues using pre-approved prescriptions or standing orders, this is now considered a breach of regulations.

• Clinics found to be administering injectables without a fresh, session-specific prescription could face Ahpra investigations, fines, or operational restrictions.

2. Only Doctors and Nurse Practitioners Can Order Stock (And They Must Work On-Site)

What’s Changed?

✅ Only medical practitioners (doctors) and nurse practitioners (NPs) can order and purchase Botox, fillers, and other Schedule 4 (S4) medications.
✅ Registered nurses (RNs) and enrolled nurses (ENs) CANNOT place stock orders themselves, even with a doctor’s approval.
✅ The prescriber placing the order must actively work at the clinic, they cannot just be listed on paperwork.

What This Means for Your Clinic:

🔹 If your clinic was ordering stock under a prescriber who doesn’t work there regularly, that is no longer allowed.
🔹 The doctor or NP must physically place the order themselves, administrative staff or non-prescribing nurses cannot do it.
🔹 Your stock must be stored only at a clinic where the prescribing doctor or NP actually works.

🚨 Risk of Non-Compliance:

• Suppliers may refuse to deliver stock if it’s ordered incorrectly.

• If an audit finds stock was ordered under a prescriber who is not actively working in the clinic, penalties could follow.

3. Stricter Rules on Stock Storage & Record-Keeping

What’s Changed?

✅ Clinics must appoint a "medicine store establisher", who must be a doctor, NP, or RN, to oversee storage and tracking of injectables.
✅ Stored stock must be directly linked to a prescriber who actively works in the clinic.
✅ Clinics must keep detailed records of stock movement, prescriptions, and administration.

What This Means for Your Clinic:

🔹 If multiple injectors work in the same clinic, you must have a clear system for tracking who prescribed, administered, and stored stock.
🔹 If your clinic was storing injectables without proper oversight, this must be corrected immediately.
🔹 You must ensure that your prescriber is actively engaged in patient care, not just signing off on stock.

🚨 Risk of Non-Compliance:

• Incorrect storage or record-keeping could result in fines, audits, or supply chain restrictions from wholesalers.

4. The Unclear "Pharmacy Dispensing" Rule – A Major Grey Area

One of the most confusing aspects of the new regulations is the mention of "dispensing", which typically means a pharmacy must fill a prescription before the patient receives the medication.

What’s Changed?

✅ The law states that each patient must have a prescription before receiving treatment, but it also refers to "dispensing."
✅ If taken literally, this could mean patients must pick up their Botox or filler from a pharmacy before bringing it to the clinic.

What This Means for Your Clinic:

🔹 If this rule is strictly enforced, patients might need to get their prescription filled at a pharmacy and bring their Botox or filler to the clinic for injection.
🔹 This creates major safety concerns, including:

• Patients improperly storing Botox/fillers (e.g., leaving them in a hot car, making them ineffective).

• Patients self-injecting at home or taking the product to an unqualified provider.

🚨 What Needs Clarification?

• Will patients actually be required to go to a pharmacy for dispensing every time they need treatment?

• Will Queensland Health issue further guidance on how this should be implemented?

🔹 For now, clinics should assume that stock can still be stored in-clinic as long as it’s ordered and managed by an on-site prescriber.

5. Nurse-Led Clinics Must Have a Doctor or NP On-Site

What’s Changed?

✅ A doctor or NP must be physically present at the clinic to prescribe and oversee treatments.
✅ Telehealth prescribing does NOT appear to be a legal solution under these rules.
✅ The prescriber must be actively engaged in patient care and clinic operations.

What This Means for Your Clinic:

🔹 Nurse injectors can no longer operate independently without a doctor or NP physically present.
🔹 A doctor cannot simply be “on-call” or listed as a prescriber on paper—they must be actively involved in the clinic.

🚨 Risk of Non-Compliance:

• If an audit reveals that a doctor or NP is not physically present when prescribing or supervising treatments, the clinic could face penalties.

What Should Clinics Do Now?

🔹 Step 1: Ensure every treatment is linked to a legally written prescription - no standing orders.
🔹 Step 2: Partner with a doctor or NP who will be actively present in your clinic.
🔹 Step 3: Check your stock ordering process - only a doctor or NP can purchase injectables.
🔹 Step 4: Clarify whether your clinic can continue storing stock, or if patients will need pharmacy dispensing.
🔹 Step 5: Stay ahead of compliance changes - more enforcement is likely coming.

🚨 These rules will fundamentally change how nurse-led clinics operate. If you need to review your compliance and avoid risks, now is the time to act.

To be continued….

QLD Health - Updated Cosmetic Injectable Guidelines. Dec 2024

Justine

hello@lunasystems.com.au